Critiquing the ‘Subject-to-Tax’ Exception via Recent Authority

By and on May 19, 2016

In this article, the authors examine recent judicial and administrative developments related to the “subject-to-tax” exception of state addback statutes and present avenues for potential challenge.

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Jane Wells MayJane Wells May
Jane Wells May focuses her practice on state and local tax matters. She represents businesses in connection with tax controversies at the audit, administrative and judicial levels around the United States. Her clients include companies in manufacturing, retailing, pharmaceuticals, financial services, agribusiness, food and beverage, health care, energy, technology and insurance industries. Jane heads the Firm's State & Local Tax Practice and sits on the Firm's Executive, Management and Compensation Committees. Read Jane Wells May's full bio.


Lauren A. FerranteLauren A. Ferrante
Lauren A. Ferrante focuses her practice on state and local taxation. She represents taxpayers at all stages of state and local controversy disputes at the audit, administrative and judicial levels. Lauren also assists taxpayers with planning, transactional, and compliance matters with respect to various state and local taxes, including income and franchise, sales and use, gross receipts and other miscellaneous taxes. Read Lauren Ferrante's full bio.

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